DCO Report: Digital Economy Hits $28 Trillion — And the EU’s DMA Review Shows What Governing It Costs

A $28 Trillion Economy Growing Three Times Faster Than Everything Else

The Digital Cooperation Organisation — the Saudi Arabia-based multilateral that spans 16 member states — published its Trends 2026 report in December 2025, drawing on surveys of more than 400 policymakers, economists, and technology leaders across 26 countries. The headline figure is striking: the global digital economy will reach $28 trillion in 2026, representing 22% of global GDP, growing at 9.5% — roughly three times the projected growth rate of the broader world economy.

That differential matters for policy. An economy growing three times faster than its host economy will, absent deliberate intervention, concentrate market power faster than existing regulatory frameworks can track. The companies that dominate the digital economy — Amazon, Google, Apple, Meta, Microsoft — have market capitalizations that exceed the GDP of most countries. Their pricing power, data access, and platform control compound with each year of above-average growth.

The DCO identifies AI as the primary driver of 2026 digital economy expansion, with AI-accelerated workforce transformation representing a nearly $4.91 trillion economic value opportunity. Digital trade transformation — cross-border e-commerce, digital services exports, integrated digital logistics — represents $3.63 trillion. Strengthening end-to-end cybersecurity — the top-ranked trend for positive socio-economic impact in the DCO survey — could unlock $3.13 trillion in economic value through reduced breach costs and improved trust.

These numbers are projections, not guarantees. But the trajectory is consistent with five consecutive years of digital economy outperformance. The governance question — who decides the rules for a 22% slice of the global economy — is not abstract. It is the central political contest of the 2020s.

The EU’s DMA: Two Years In, and It’s Working

The European Commission published its formal two-year DMA review on April 28, 2026. The headline finding: the Digital Markets Act is fit for purpose and does not need to be revised. The Commission’s first noncompliance decisions — rendered on April 23, 2026 — imposed fines of €500 million on Apple and €200 million on Meta.

Apple’s violation centered on anti-steering: Apple was found to have restricted app developers from informing users about offers available outside the App Store, in breach of Article 5(4) DMA. Meta’s violation concerned personal data: the Commission found that Meta’s requirement for users to consent to personal data combination across its services breached Article 5(2) DMA, which governs cross-platform data reuse.

These are not symbolic fines. €700 million combined represents a meaningful — if small relative to Apple’s quarterly profits — regulatory cost. More significantly, the EU’s enforcement actions in 2026 have triggered the first explicit US government threat of trade retaliation: the Trump administration warned of 25% tariffs on EU goods in response to what it characterized as discriminatory targeting of American technology companies. The DMA’s success in imposing compliance costs is now generating geopolitical friction.

The DMA’s documented successes by April 2026 include browser and search engine choice menus on smartphones, the ability to uninstall pre-installed applications, third-party app store authorization, and WhatsApp messaging interoperability with rival platforms. These are consumer wins. They are also friction introductions — making certain digital workflows more cumbersome in exchange for more competitive choice.

What the Two-Year Review Reveals About Governing a $28 Trillion Economy

1. Enforcement speed is the DMA’s primary limitation

The DMA’s structural weakness is not its legal framework — it is investigation timelines. The Apple and Meta fines were imposed for violations that investigations opened a year earlier had documented. For a digital economy growing at 9.5% annually, a 12-18 month enforcement cycle means that the market structure being enforced against is already materially different by the time the fine lands. Google is under investigation for Search self-preferencing, Google Play Store conduct, and advertising technology practices that were first flagged in 2024-2025. By the time enforcement decisions land, Google will have already adapted or the market will have moved.

The April 2026 DMA review explicitly names AI and cloud as priority enforcement areas — an expansion of scope that will require the Commission to build new investigative capabilities and longer investigation cycles than the first generation of social media and app store cases. The governance infrastructure is playing catch-up to a $28 trillion economy.

2. Interoperability requirements are more powerful than fine threats

WhatsApp’s messaging interoperability requirement — compelling Meta to allow rival messaging apps to exchange messages with WhatsApp users — is structurally more impactful than any fine. A €200 million fine for data misuse is a cost of doing business for a company with $130+ billion in annual revenue. Mandatory interoperability, if broadly extended, restructures the competitive architecture of the platform economy: it converts network effects from a moat into a shared resource.

ComplianceHub’s analysis of the DMA review notes that the Commission intends to extend interoperability requirements to cloud services — potentially requiring AWS, Azure, and Google Cloud to enable customer data portability across hyperscaler boundaries. If implemented, that would be the most significant platform market intervention since Microsoft’s browser bundling case in the late 1990s. Enterprise technology buyers should monitor the cloud interoperability proceedings closely.

3. US-EU regulatory divergence is now a business risk, not a policy debate

The tariff threat triggered by the DMA fines signals a phase transition in US-EU digital regulation relations. For the past decade, transatlantic digital governance disputes centered on data privacy (GDPR, Privacy Shield), with companies managing the complexity through data localization and consent frameworks. The DMA introduces a new dimension: structural platform competition rules that the US government explicitly views as protectionist targeting of American companies.

For multinationals operating across US and EU markets, this divergence creates compliance tension. A platform architecture designed to comply with DMA interoperability requirements may create antitrust exposure under US law (which views mandatory data sharing with competitors differently). Legal and compliance teams at companies above the DMA’s gatekeeper threshold — €7.5 billion in annual EU revenue or 45 million monthly active EU users — should conduct a cross-jurisdictional compliance audit that maps DMA requirements against US competition law, FTC guidance, and emerging state-level platform regulations.

What Comes Next

The DCO’s $28 trillion projection and the DMA’s two-year report arrive at the same moment: a digital economy accelerating past any prior governance framework’s design parameters, with regulators worldwide improvising responses to market structures that did not exist when most regulatory agencies were built.

The EU’s bet — that ex-ante rules for designated gatekeepers are more effective than ex-post antitrust enforcement — is being tested in real time. The early evidence is mixed: browser choice menus are implemented, app stores are opening, messaging is interoperating. The deeper structural distortions — search self-preferencing, advertising technology monopoly, AI model access controls — remain under investigation and unresolved.

Euronews’ analysis of the DMA review captures the fundamental tension: the regulation introduced friction in exchange for competition, and the trade-off is not yet clear to consumers who experience the friction daily without necessarily seeing the competition improve. The governance infrastructure for a $28 trillion digital economy is being built in public, under political pressure, with incomplete information about what it is governing. That is the honest answer to whether the DMA “works.”

Frequently Asked Questions

Sources & Further Reading

• Digital Economy Expected to Grow 9.5% within the Global Economy — IT News Africa / DCO
• Two Years of DMA: Does It Really Work? — Euronews
• The DMA’s Teeth: Meta and Apple Fined by the European Commission — Kluwer Competition Law Blog
• EU DMA Review: AI and Cloud Are Now Priority Enforcement Areas — ComplianceHub
• The European Union Shifts From Negotiations to Strict Enforcement — SFG Media